Compare
Four regions, side by side.
A short summary of each row, with a link to the detail. Columns follow My regions in the header.
For reference purposes only. Not legal advice.
SimplifiedA short side-by-side summary. Each region has exceptions and thresholds; use the linked region page and its sources. Cells marked 'Not settled' reflect rules that may change.Source: European Commission: AI Act overview · Checked 2 Oct 2026
| Row | European Union | United States | United Kingdom | India |
|---|---|---|---|---|
| Overall approach | Risk-based AI regulation plus data protection and product law | No comprehensive federal statute; executive action, existing laws and a growing set of state laws Not settled This item may change. See the region page's "Watch this" note. | Principles-based; existing regulators apply AI principles | Voluntary national guidelines plus binding IT rules and data protection law |
| AI-specific binding law | Yes (EU AI Act, phased) | Not federally; yes in some states | No Not settled This item may change. See the region page's "Watch this" note. | Partly (rules on synthetic content) |
| Risk-based classification | Yes, four tiers | Some state laws focus on consequential or automated decisions Not settled This item may change. See the region page's "Watch this" note. | No statutory tiers; context-based | Not in law; guidelines encourage proportionate, risk-based practice Not settled This item may change. See the region page's "Watch this" note. |
| Transparency and labelling | Article 50 duties, including marking of AI-generated content, from 2 Aug 2026 (existing systems: marking by 2 Dec 2026) | Varies by state (for example disclosure in Utah, training-data and frontier transparency in California) | Through existing law and regulator guidance | Labelling and provenance metadata for synthetic content by intermediaries since 20 Feb 2026 |
| Automated decision rights | GDPR rules on solely automated decisions | California rules from 1 Jan 2027; Colorado from 1 Jan 2027 Not settled This item may change. See the region page's "Watch this" note. | UK GDPR as amended by the Data (Use and Access) Act 2025: significant automated decisions allowed with safeguards, reported in force since 5 Feb 2026 Not settled This item may change. See the region page's "Watch this" note. | Data protection rights under the DPDP Act; no AI-specific decision right Not settled This item may change. See the region page's "Watch this" note. |
| AI in employment | High-risk from 2 Dec 2027 | New York City Local Law 144; Illinois HB 3773; Colorado and California from 2027 Not settled This item may change. See the region page's "Watch this" note. | Equality Act 2010 and data protection law | DPDP Act for employee data; general law |
| Frontier models | General-purpose AI duties since 2 Aug 2025 | California SB 53 (2026); New York and Illinois laws from 2027 Not settled This item may change. See the region page's "Watch this" note. | AI Security Institute evaluations; no statute Not settled This item may change. See the region page's "Watch this" note. | No specific rules |
| Data protection law | GDPR | Sector and state privacy laws; no comprehensive federal law | UK GDPR, Data Protection Act 2018, Data (Use and Access) Act 2025 | DPDP Act 2023 and Rules 2025 (phased) Not settled This item may change. See the region page's "Watch this" note. |
| Main regulators | AI Office, national market surveillance authorities, data protection authorities | FTC, EEOC, CFPB and sector regulators; state attorneys general | ICO, FCA, CMA, Ofcom, MHRA, EHRC | MeitY, Data Protection Board, RBI, SEBI |
| Next key date | 2 Dec 2026 (new prohibitions; marking deadline for existing systems) | 1 Jan 2027 (several state laws) Not settled This item may change. See the region page's "Watch this" note. | Watch: Regulating for Growth Bill and any AI bill Not settled This item may change. See the region page's "Watch this" note. | 13 Nov 2026 and 13 May 2027 (DPDP phases) Not settled This item may change. See the region page's "Watch this" note. |
Cells marked "Not settled" reflect rules that may change; see each region page's "Watch this" section. Short summaries leave out exceptions and thresholds.
Reviewed 2 Oct 2026. Sources: European Commission: AI Act overview.
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